This report is used to identify certain national bank operating subsidiaries (OS) that are subject to OCC supervisory authority. This report identifies a bank’s operating subsidiaries that do business directly with consumers in the United States and are not functionally regulated as defined in section 5(c)(5) of the Bank Holding Company Act of 1956, as amended (12 USC 1844(c)(5)). Specifically, an OS does business directly with consumers if it provides products or services to individuals to be used primarily for personal, family, or household purposes.

No legal advice here

Although this blog is chock full of legal information, there isn't a bit of legal advice to be found anywhere. Legal advice is what you get from a lawyer who is familiar with you and your problems. If you are in need of legal advice, your best bet is to ask a lawyer.